CMS Seeks Input on New 'Reasonable and Relevant' Standards for Medicare Part D Pharmacy Contracts
The RFI implements a 2026 appropriations law provision ahead of a 2029 effective date
BLUF: The Centers for Medicare & Medicaid Services issued a Request for Information on September 24, 2026 to help set new "reasonable and relevant" standards for Medicare Part D pharmacy network contract terms.
CMS published the RFI seeking industry input on standards for Part D plan sponsors' contract terms with network pharmacies, as required by Section 6223(a) of the Consolidated Appropriations Act, 2026. The provision amends the Social Security Act to require that, starting with plan years beginning January 1, 2029, standard pharmacy contract terms offered by Part D plan sponsors be "reasonable and relevant" under criteria the HHS Secretary must establish.
Why it matters: This RFI is a precursor to future rulemaking that will directly govern how Part D plan sponsors and pharmacy benefit managers structure network contracts — a subject pharmacy trade groups have pressed for years over concerns about below-cost reimbursement and restrictive network terms. Contractors and consultants supporting CMS on Medicare Part D program integrity, network adequacy, or PBM oversight work should track this docket closely, since RFI responses typically shape the substance of the proposed rule CMS must issue ahead of the 2029 effective date.
By the numbers:
- Publication date: September 24, 2026
- Document type: Proposed Rule (RFI)
- Statutory basis: Section 6223(a), Consolidated Appropriations Act, 2026
- New standards take effect: plan years beginning January 1, 2029
- Issuing agency: Centers for Medicare & Medicaid Services (HHS)
The underlying statute requires the HHS Secretary to establish standards for what counts as a "reasonable and relevant" pharmacy contract term, and requires the Secretary to issue this RFI as the first formal step. CMS is soliciting comment before formalizing those standards, which will apply to all Part D plan sponsors' network pharmacy agreements once in effect.
Source: Federal Register
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